Scroggins v. State, 2012 Ark. App. 87

Glover presided over Terry Scroggins’s guilty plea to violating Arkansas’s hot-check law, sentencing him to three years’ probation with costs, fines, restitution, and DNA fees.
Restitution of $347.37 was entered, payable in installments starting July 1, 2009, with credit for 17 days in jail and monthly payment obligations ($50 monthly feed or specified amounts).
Probation required Scroggins to pay the ordered costs, fines, restitution, and fees; credit and timing details were recorded in the court file.
On October 12, 2010, the State filed a petition to revoke alleging Scroggins possessed firearms, but the revocation hearing primarily addressed nonpayment.
The trial court revoked probation and sentenced Scroggins to five years in the Arkansas Department of Correction.
Scroggins appealed alleging (a) lack of evidence that probation terms were introduced, (b) procedural voidness and insufficiency of proof.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did failure to formally introduce probation terms require reversal?	Scroggins argues lack of introduced terms violated proof.	State contends terms awareness suffices; not reversible.	Not reversible; terms need not be formally introduced if in record.
Was the revocation unsupported due to notice and payment-deficiency proof?	Scroggins asserts notice and nonpayment proof insufficient.	State contends proof of nonpayment plus attributed deficiencies show violation.	Affirmed; State proved deficiency and burden-shifting upheld; evidence supported revocation.

Nelson v. State, 84 Ark.App. 378 (2004) (procedural requirement to raise probation-terms issues below)
Whitener v. State, 96 Ark.App. 354 (2006) (failure to introduce terms is procedural objection; not raised below)
Costes v. State, 103 Ark.App. 171 (2008) (proof of written conditions is procedural; dissent noted; adherence to precedent)
Beck v. State, 317 Ark. 154 (1994) (recognizes record must reflect awareness of conditions in governing revocation)